MEMORANDUM FINDINGS OF FACT AND OPINION
DEAN, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b) and Rules 180, 181, and 182.
In two separate notices of deficiency respondent determined additions to petitioners' Federal income taxes for the years 1983 and 1984 under section 6653(a)(1) in the amounts of $1,159.70 and $43.65, respectively...
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